This paper establishes a unified a posteriori error estimator for a large class of conforming finite element methods for the Reissner-Mindlin plate problem. The analysis is based on some assumption (H) on the consistency of the reduction integration to avoid shear locking. The reliable and efficient a posteriori error estimator is robust in the sense that the reliability and efficiency constants are independent of the plate thickness t. The presented analysis applies to all conforming MITC elements and all conforming finite element methods without reduced integration from the literature.